[rpd] Resources transfer policy Proposal

[Anthony Ubah]

Hello Alain Aina and Co.,

In addition to my previous concerns, I find that with this new Resources
transfer policy proposal, Business, Eg. Internet Service providers and
other service providers (Example businesses offer as-a-Service products
like IaaS and PaaS, also FTTH/FTTP, etc.) would be restricted from
assigning IP addresses to customers without permission from AfriNIC.


Thus I suggest a full resource transfer policy is needed for effective
resource exchange.

Kind regards,

Anthony


On Fri, Aug 30, 2019 at 1:47 AM Anthony Ubah <ubah.tonyiyke at gmail.com>
wrote:


> Hello Alain Aina and Co.,

>

> There certainly is a need for a full resource transfer policy to attempt

> fixing some of the lapses in the current Intra-RIR transfer policy.

> Thus this is a very interesting proposal, a good one to say the least.

>

> I need a little clarity on some a little details;

>

>

> Section 2:

> Excerpt;

>

> *“The goal of this transfer policy is to help distribute resources from

> those who no longer need them to organizations that need the resources, but

> cannot obtain them from the AFRINIC free pools.”*

> Redistribution of resources in not remotely a responsibility of AfRINIC. I

> suggest you consider reviewing this statement. I feel the new policy will

> create an avenue for resources to be transferred organically in a

> transparent system.

>

>

> Section 3.6:

> The section describes the Conditions on the recipient of “resources”

> Excerpts;

>

>

>

>

>

>

>

>

>

>

>

> * “…..- Recipient that does not have prior resources must: ++ demonstrate

> a detailed plan for the use of the transferred resources(in the case of

> ASN, recipient must meet the criteria for assignment of ASN).- Recipient

> with prior resources must:++ demonstrate a detailed plan for the use of the

> transferred resources(in the case of ASN, recipient must meet the criteria

> for assignment of ASN).++ Show past usage rate.++ Provide evidence of

> compliance with AFRINIC policies with respect to past

> allocations/assignments.…..”*As widely quoted, AfRINIC IPv4 pool is

> expected to run out soon, unfortunately, I feel the above conditions

> creates a limiting factor and thus does not necessarily encourage massive

> resource inflow into the region as the region would hope for.

>

> My concerns include;

>

> 1.     A new business with no existing regional resources might have

> difficulty or be forbidden from transferring resource into the region.

>

> 2.     How can one satisfactorily demonstrate a detailed plan for the use

> of the transferred resources? Will business projections suffice?

>

> 3.     Will past usage rate of a resource owner in another region suffice?

>

>

>

> Thanks for the good work put in, in this proposal.

>

> Kind Regards,

>

> Anthony

>


On Thu, Aug 29, 2019 at 1:00 PM <rpd-request at afrinic.net> wrote:


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> Today's Topics:

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>    1. Resources transfer policy Proposal (ALAIN AINA)

>

>

> ----------------------------------------------------------------------

>

> Message: 1

> Date: Thu, 29 Aug 2019 11:36:28 +0000

> From: ALAIN AINA <aalain at trstech.net>

> To: rpd at afrinic.net

> Subject: [rpd] Resources transfer policy Proposal

> Message-ID: <74B25009-9B77-4793-9446-BB7E94CE6760 at trstech.net>

> Content-Type: text/plain;       charset=utf-8

>

> Dear community

>

> A new policy proposal  named "AFRINIC  resources transfer policy" is

> submitted for discussions. This proposal obsoletes the current  IPv4

> transfer within AFRINIC  service region policy,  defines  rules for

> transfers of IPv4  and ASNs  within the region and between AFRINIC service

> region and other regions.

>

> The policy allows a category of resources to be transferred out of the

> region, another category of resources to be transferred inside and denies

> the transfer of certain resources.

>

> We expect this to be a response to a harmonised policy which addresses

> some of the limitations of the intra-rir policy and proposes a solution for

> an inter-rir transfer  which minimizes the foreseen risks of uncontrolled

> outflow of resources.

>

> The co-authors

>

>

> =====================begin=================

> Draft Policy Name: AFRINIC Number resources transfer policy

> ID: (Assigned by AFRINIC)

> Submission Date: 29 August 2019

> Version: 1.0

> Author(s): (a) Name, (b) Email address, (c) Affiliation, if applicable

>       Gregoire Olaotan Ehoumi, gregoire at ehoumi.net, independent

>       Mukhangou Noah  Maina, noah.maina at seacom.com, SEACOM

>       Komi Elitcha,  kelitcha at djesido.africa, Independent

>       Adeola A. P. Aina, alain.aina at wacren.net, WACREN

>

> Sections of Policy Manual affected

>

> Obsoletes: IPv4 Resources transfer within the AFRINIC Region (Section 5.7

> of the CPM)

>

> 1.      Summary of the problem being addressed by this proposal

>

> AFRINIC IPv4 pool is expected to run out soon. Some entities may need IPv4

> space to support their IPv6 deployments, especially to support transition

> mechanisms, which AFRINIC may not meet. The current Intra-RIR policy in

> force at AFRINIC allows entities to receive unused IPv4 address from other

> members solely within the AFRINIC region, based on justified needs.

> Considering the limited IPv4 space initially made available to AFRINIC

> (AFRINIC managing only 7.23 /8 with a very low ratio of IPv4 addresses per

> Internet users), there will therefore be a need to allow for unused IPv4

> from other regions to move into AFRINIC service region ? this without

> necessarily depleting AFRINIC's slim amount of IPv4 addresses by

> transferring space out of the region.

>

> The current Intra-RIR transfer policy allows all types of IPv4

> allocations/assignments to be transferred, including IPv4 from special

> purpose blocks (reserved blocks for IXPs and DNS root ops, Last /8, etc.)

>

> The current intra-RIR transfer policy does not cover ASNs while there are

> cases where transfers of ASNs among AFRINIC members is desirable.

>

>

> 2.      Summary of how this proposal addresses the problem

>

> This new policy defines a set of rules to allow transfer of IPv4 addresses

> and ASNs within AFRINIC service region and between AFRINIC service region

> and other regions by specifying what categories of resources are eligible

> for transfer, the location of parties (sources and recipients) and the

> conditions to be met.

> The policy segregates the resources in different categories and defines

> which transfer rules applied to each category.

>

> Only Legacy resources and resources previously transferred from other

> regions will be transferable out of the AFRINIC service region.

>

> It also states the following:

>

> Number resources are non-transferable and are not assignable to any other

> organisation unless AFRINIC has expressly and in writing approved a request

> for transfer. AFRINIC is tasked with making prudent decisions on whether to

> approve the transfer of number resources.

>

> IPv4 addresses and ASNs can be transferred only in accordance with the

> following policy. AFRINIC does not recognise transfers outside of this

> policy and its predecessor and requires organisations holding such

> resources to return them to the appropriate registries.

>

> The goal of this transfer policy is to help distribute resources from

> those who no longer need them to organisations that need the resources, but

> cannot obtain them from the AFRINIC  free pools.

>

> AFRINIC recognizes the following types of transfers:

> - merger, acquisition or takeover,

> - between AFRINIC members,

> - between an AFRINIC member and a member of another RIR,

> - between a Legacy holder and an AFRINIC member,

> - between a Legacy holder and a member of another RIR.

>

> AFRINIC will process and record Inter-RIR resource transfers only when the

> counterpart RIR has an Inter-RIR transfer policy that permits the transfer

> of IPv4 address space and ASNs between its own region and AFRINIC.

>

>

> 3.      Proposal

>

> 3.1 Definitions

>

> 3.1.1 ?Resource? refers to IPv4 Address space or Autonomous System Numbers.

> ?AFRINIC pool? means AFRINIC managed pool of IPv4 and ASNs, obtained from

> IANA (allocated and recovered) or through the ERX (Early registration

> transfers).

>

> 3.1.2 ?Special-Purpose pool? means the pool of resources currently

> reserved for Critical Internet Infrastructures (section 5.6.4 of CPM) and

> last /8 (section 5.4.1 of CPM).

>

> 3.1.3 ?Legacy resources? refer to resources allocated prior to the RIR

> system and tagged as Legacy by AFRINIC.

>

> 3.1.4 ?Others? means resources transferred from other regions through

> Inter-RIR transfer.

>

> 3.1.5 ?Inter-RIR transfer? means the transfer of resources from an AFRINIC

> member to a member of another RIR or vice-versa.

>

>

> 3.2 Marking of the resources

>

> AFRINIC pool == Regional

> Special-Purpose pool == Reserved

> Legacy == Legacy

> Others == Global

>

> 3.3 Rules and procedures for selecting resources eligible for transfers

>

> 3.3.1 If source and recipient are AFRINIC members, then allow ?Regional?,

> ?Global? or ?Legacy? for transfer and mark transferred ?Legacy? as ?Global?

>

> 3.3.2 If source is Legacy holder and recipient is AFRINIC member, then

> allow ?Legacy? for transfer and mark transferred resources as ?Global?

>

> 3.3.3 If source is Legacy holder and recipient is in another region, then

> allow ?Legacy? for transfer

>

> 3.3.4 If source is AFRINIC member and recipient is in another region, then

> allow ?Global? for transfer

>

> 3.3.5 If source is from another region and recipient is AFRINIC member,

> then allow ?Any?, and then mark the transferred resources as ?Global?

>

> 3.3.6 Irrespective of the source and recipient, if resource to be

> transferred is ?Reserved? then deny transfer.

>

> 3.4 Conditions on resources to be transferred

>

> - The size of the IPv4 address should be a minimum of /24.

> - The resource must qualify for type of transfer requested.

> - The resource will be covered by AFRINIC policies after transfer into the

> region.

>

> 3.5 Conditions on the source

>

> - Must be right holder of the resources to be transferred with no disputes.

> - If the source is from other regions, conditions on the source are

> defined in the counterpart RIRs transfer policy.

>

> 3.6 Conditions on the recipient

>

> - Will be subject to current AFRINIC policies.

> - Must sign RSA.

> - Recipient that does not have prior resources must:

>  ++ demonstrate a detailed plan for the use of the transferred resources

> (in the case of ASN, recipient must meet the criteria for assignment of

> ASN).

> - Recipient with prior resources must:

> ++ demonstrate a detailed plan for the use of the transferred resources

> (in the case of ASN, recipient must meet the criteria for assignment of

> ASN).

> ++ Show past usage rate.

> ++ Provide evidence of compliance with AFRINIC policies with respect to

> past allocations/assignments.

> - If the recipient is in another region, the conditions on the recipient

> are defined in the counterpart?s RIR transfer policy.

>

> 4.      Revision History

>

> v1 submitted on 29/08/2019 for discussions

>

> 5.      References

>

> https://www.nro.net/wp-content/uploads/NRO-Statistics-2019Q2.pdf

> https://www.potaroo.net/tools/ipv4/

> http://bgp.potaroo.net/iso3166/v4cc.html

> http://resources.potaroo.net/iso3166/ascc.html

> ftp://ftp.afrinic.net/stats/afrinic/transfers/

>

> ===================end=======================

>

>

>

>

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